The advertising for Facebook.com which appeared on the Facebook page of a local business in Langport (UK) featured a radius map with Langport at its centre. The following text was provided alongside the map:
“Reach people close by
120,000 people within 15 kilometres Langport
You could reach up to 120,000 people on Facebook who are within 15 kilometres of your business location. Promote local business.”
The complainant said that he considered the claim that he could reach 120,000 by advertising his business on Facebook to be so factually incorrect that it had to be misleading. He said as Facebook was able to pinpoint the location of his business they should also know that the population(1) of the area surrounding his business in Langport, a small town in Somerset in the UK, was far less than 120,000 people.
The advertisers said the Estimated Reach tool used by them looked at where the pin is dropped by the advertiser and estimates out a standard 15km radius. They said that the tool did not actually determine how many people lived in the specific area and its surroundings (where the pin had been dropped). After conducting a review of what happened in this case, and researching the population in the city where the pin was dropped, they said it seemed that the tool in error overestimated the potential opportunity to the business in question. They said they did not have a maps product that would inform their system of how populated the surrounding area actually was. Therefore, the tool estimated a much greater potential audience than was accurate in the real world. They pointed out, however, that the numbers indicated, were supposed to merely aide in providing an estimate to advertisers to help with ad planning and were not meant to be viewed as real population numbers.
In the interest of clarity the advertisers pointed out that the estimated reach had no effect on actual delivery of a company’s advertising or what they paid for it. They said the billing and reporting for advertising was completely separate and the advertiser only paid for the advertising which Facebook actually delivered, irrespective of estimated reach.
In conclusion, the advertisers said that the Estimated Reach tool continued to change and develop and they were constantly improving their methodology for its development. They reiterated, however, that as they did not currently have a maps product which would help inform them as to the actual population of an area, the tool was liable to occasionally make the type of over estimation referenced in the complaint. Nonetheless, they said, they clearly stated that the functionality of the product itself was ‘estimated’ and that it was clearly an aide to attempt to estimate potential reach, and that it was not being used by them for advertising purposes to attract users to place advertising with them.
The Complaints Committee considered the details of the complaint and the advertisers’ response. The Committee noted that the Estimated Reach tool was intended to be an aide to companies planning ad campaigns on Facebook. They also noted however that it was not currently possible for the tool to know the actual population of an area, and as in the case under complaint, there could be significant disparities between the ‘estimated’ population and the actual population.
In the circumstances, the Complaints Committee considered, notwithstanding the qualification of ‘up to’, the return of significant over-estimates of populations was likely to mislead potential customers.
The Committee concluded that the advertising was in breach of Sections 4.1, 4.4, 4.9, and 4.10 of the Code”.
The Estimated Reach tool should not be referenced in marketing communications until the advertisers can demonstrate that they have upgraded its level of accuracy.